UNITED STATES OF AMERICA
Before the
SECURITIES AND EXCHANGE COMMISSION

INVESTMENT ADVISERS ACT OF 1940
Release No. 2296 / September 15, 2004

ADMINISTRATIVE PROCEEDING
File No. 3-11663

In the Matter of

SAGAM CAPITAL MANAGEMENT CORP. AND SAGAM CAPITAL LLC,

Respondent.

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ORDER INSTITUTING ADMINISTRATIVE PROCEEDINGS PURSUANT TO SECTION 203(e) OF THE INVESTMENT ADVISERS ACT OF 1940, MAKING FINDINGS, AND IMPOSING REMEDIAL SANCTIONS

I.

The Securities and Exchange Commission ("Commission") deems it appropriate and in the public interest that public administrative proceedings be, and hereby are, instituted pursuant to Section 203(e) of the Investment Advisers Act of 1940 ("Advisers Act") against Sagam Capital Management Corp. ("Sagam Corp.") and Sagam Capital LLC ("Sagam LLC") (collectively the "Respondents").

II.

In anticipation of the institution of these proceedings, the Respondents have submitted Offers of Settlement (the "Offers") which the Commission has determined to accept. Solely for the purpose of these proceedings and any other proceedings brought by or on behalf of the Commission, or to which the Commission is a party, and without admitting or denying the findings herein, except as to the Commission's jurisdiction over them and the subject matter of these proceedings, and the findings contained in Section III.3, which are admitted, Respondents consent to the entry of this Order Instituting Administrative Proceedings Pursuant to Section 203(e) of the Investment Advisers Act of 1940, Making Findings, and Imposing Remedial Sanctions ("Order"), as set forth below.

III.

On the basis of this Order and Respondents' Offers, the Commission finds that:

1. Sagam Corp. has been registered with the Commission as an investment adviser since August 10, 1989. It is a Delaware corporation with its principal place of business in New York, New York. Yehuda Shiv ("Shiv") was the President of Sagam Corp. until December 10, 2001. On December 10, 2001, the Commission filed SEC v. Yehuda Shiv, et al., 01CV11282 (S.D.N.Y.) (AKH) ("SEC v. Shiv") alleging that Sagam Corp. violated the antifraud provisions of the Securities Act of 1933 ("Securities Act"), Securities Exchange Act of 1934 ("Exchange Act"), and Investment Advisers Act of 1940 ("Advisers Act"). On December 12, 2001, the Court appointed a receiver who took control of Sagam Corp.

2. Sagam LLC has been registered with the Commission as an investment adviser since April 21, 1998. It is a Delaware corporation with its principal place of business in New York, New York. Shiv was the president of Sagam LLC until December 10, 2001. On December 10, 2001, the Commission filed SEC v. Shiv alleging that Sagam LLC violated the antifraud provisions of the Securities Act, Exchange Act, and Advisers Act. On December 12, 2001, the Court appointed a receiver who took control of Sagam LLC.

3. On July 31, 2002, the Court in SEC v. Shiv entered a partial judgment, on consent, permanently enjoining Sagam Corp. and Sagam LLC from future violations of Section 17(a) of the Securities Act, Section 10(b) of the Exchange Act and Rule 10b-5, and Sections 206(1) and 206(2) of the Advisers Act.

4. The Commission's complaint alleged that from 1995 to December 2001, in connection with the purchase and sale of securities, Sagam Corp. and Sagam LLC created and delivered false and misleading account statements to their investment advisory clients and misappropriated assets in their clients' accounts.

IV.

In view of the foregoing, the Commission deems it appropriate and in the public interest to impose the sanctions agreed to in the Respondents' Offers.

ACCORDINGLY, IT IS HEREBY ORDERED:

Pursuant to Section 203(e) of the Advisers Act, that Respondents' investment adviser registrations be, and are hereby revoked.